EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; REFUSAL TO PROVIDE INFORMATION – Confidentiality; Privacy

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In determining whether to order employer to provide information, PERB considers union’s promise to keep the information confidential. The Board noted that unions are commonly entrusted with private employee information, as “[o]ne of the consequences of collective bargaining is that it subordinates the particular interests of individual employees to the collective interest of the unit.” (Los Angeles Unified School District (2015) PERB Decision No. 2438, p. 11, citation omitted.) (pp. 10-11.)